Gloria Walker, et al. v. Doug Burgum, et al.

Summary

The United States District Court for the Northern District of California denied a motion by individuals claiming membership in the historic Table Mountain Band of Indians to enforce or modify a 1983 stipulated judgment. The court held that the movants were not parties or members of the certified classes, that the motion was untimely under 28 U.S.C. § 2401(a), and that the court lacked jurisdiction, including ancillary jurisdiction, to grant the requested relief. The motion was denied without leave to amend.

Holdings

1. The motion was untimely because the movants filed it more than six years after they knew or reasonably should have known of the alleged injury, and they offered no credible basis for extending the limitations period.
2. The movants could not use the potential treatment of some APA § 706(1) failure-to-act claims to avoid the limitations bar because they had not asserted an underlying APA claim.
3. The court lacked ancillary jurisdiction to enforce the 1983 stipulated judgment because the judgment's one-year retention-of-jurisdiction period had expired, and the movants were not parties to or members of the certified classes.
4. Rule 60(b)(6) did not authorize the requested enforcement relief, and in any event the motion was not brought within a reasonable time or supported by extraordinary circumstances.

Questions Presented

1. Whether the movants' Rule 60(b)(6) motion to enforce the 1983 stipulated judgment was barred by the six-year limitations period in 28 U.S.C. § 2401(a).
2. Whether the movants' invocation of 5 U.S.C. § 706(1) avoided the limitations problem despite the absence of an underlying Administrative Procedure Act claim.
3. Whether the court retained ancillary jurisdiction to enforce the 1983 stipulated judgment more than forty years after entry, despite the judgment's one-year retention-of-jurisdiction provision and the movants' nonparty status.
4. Whether Rule 60(b)(6) supplied jurisdiction or otherwise authorized the requested enforcement relief.
5. Whether the motion was brought within a reasonable time and whether extraordinary circumstances justified relief under Rule 60(b)(6).

Disposition

other